Paul Weiss Discusses Review of Dodd-Frank Provisions

On April 21, 2017, President Trump signed two presidential memoranda calling for review of portions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). These presidential memoranda follow the executive order signed on February 3 (see our client alert here) setting forth “Core Principles” intended to guide the regulation of the U.S. financial system.

Orderly Liquidation Authority

The first presidential memorandum (available here) directs the Secretary of the Treasury to review the Dodd-Frank Orderly Liquidation Authority, which provides a mechanism for the seizure, break up and winding down of a failing non-bank … Read more

Paul Weiss Offers Lessons Learned from the OCC Review of Wells Fargo Sales Practices

On April 19, 2017, the Office of the Comptroller of the Currency (“OCC”) released its “Lessons Learned Review of Supervision of Sales Practices at Wells Fargo.”[i] The report results from Comptroller Thomas Curry’s directive for an “independent review” of the Wells Fargo supervisory record to “identify any supervision gaps and lessons learned to improve the OCC’s supervisory processes going forward.”

The OCC report mirrors some of the themes of the Wells Fargo investigation report, which we have discussed in a prior memorandum.[ii] According to the OCC report, examiners missed opportunities to probe more deeply into sales practices problems, search for … Read more